EIN: 237345990
UEI: SKLLSWE59N77
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 11, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 11, 2026 (74 days ago).
What is a management decision? →Some of the rent reasonableness determinations were incorrectly performed. Cause: Internal controls are insufficient to ensure the rent reasonableness test is consistently calculated accurately and that appropriate supporting documentation is properly maintained. Effect: The organization may accidently provide rental assistance that is not in compliance with HUD guidelines. Questioned costs: Known and likely questioned costs are under $25,000. Audit Recommendation: We recommend the organization review and strengthen its written policies and procedures for rent reasonableness determinations. This should include ensuring consistent application of the methodology and maintaining complete supporting documentation for all rental assistance provided, in compliance with federal program requirements. In addition, we recommend that someone independent of the preparer perform periodic reviews of the rent reasonableness tests. Management’s Response: When placing a new participant in a HUD funded housing program, or upon relocation of an existing participant, Program Management will conduct a review of the staff prepared Utility Allowance and Rent Reasonable documentation to confirm calculations have been completed accurately and all supporting documentation is present. Program Management will indicate by signature on the File Checklist that they have confirmed all Utility Allowance and Rent Reasonable documentation is present and accurate. The File Checklist is submitted to fiscal prior to first payment for a new participant and upon relocation of an existing participant. Program Management will conduct a retrospective review of all current files to ensure Utility Allowance and Rent Reasonable documentation is completed accurately and all supporting documentation is present.
Show full finding ▾Hide full finding ▴Finding Number: 2025-001 Finding Type: Federal award finding Federal Assistance Listing No.: 14.267 Program Name: Continuum of Care Program Federal Agency: U.S. Department of Housing and Urban Development Grant Number: WA0361L0T082308 Federal Award Period: October 1, 2024 through September 30, 2025 Pass-Through Entity: Multnomah County Grant Number: JOHS-SVCSGEN-15516-2023 Federal Award Period: July 1, 2023 through June 30, 2025 Control Deficiency Type: Significant deficiency over compliance Compliance Requirement: Special Tests and Provisions Repeat Finding: Yes. Prior audit finding no. 2024-001 Criteria: The Uniform Guidance in 2 CFR 200.303 requires that non-Federal entities receiving federal awards establish and maintain internal controls that provide reasonable assurance that the subrecipient is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Per 24 CFR 578.51(g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or sub-recipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for a comparable unassisted unit, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: Some of the rent reasonableness determinations were incorrectly performed. Cause: Internal controls are insufficient to ensure the rent reasonableness test is consistently calculated accurately and that appropriate supporting documentation is properly maintained. Effect: The organization may accidently provide rental assistance that is not in compliance with HUD guidelines. Questioned costs: Known and likely questioned costs are under $25,000. Audit Recommendation: We recommend the organization review and strengthen its written policies and procedures for rent reasonableness determinations. This should include ensuring consistent application of the methodology and maintaining complete supporting documentation for all rental assistance provided, in compliance with federal program requirements. In addition, we recommend that someone independent of the preparer perform periodic reviews of the rent reasonableness tests. Management’s Response: When placing a new participant in a HUD funded housing program, or upon relocation of an existing participant, Program Management will conduct a review of the staff prepared Utility Allowance and Rent Reasonable documentation to confirm calculations have been completed accurately and all supporting documentation is present. Program Management will indicate by signature on the File Checklist that they have confirmed all Utility Allowance and Rent Reasonable documentation is present and accurate. The File Checklist is submitted to fiscal prior to first payment for a new participant and upon relocation of an existing participant. Program Management will conduct a retrospective review of all current files to ensure Utility Allowance and Rent Reasonable documentation is completed accurately and all supporting documentation is present.
Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: When placing a new participant in a HUD funded housing program, or upon relocation of an existing participant, Program Management wil l conduct a review of the staff prepared Utility Allowance and Rent Reasonable documentation to confirm calculations have been completed accurately and all supporting documentation is present. Program Management will indicate by signature on the File Checklist that they have confirmed all Utility Allowance and Rent Reasonable documentation is present and accurate. The File Checklist is submitted to the fiscal department prior to first payment for a new participant and upon relocation of an existing participant. Program Management will conduct a retrospective review of all current files to ensure Utilit y Allowance and Rent Reasonable documentation is completed accurately and all supporting documentation is present. Anticipated Completion Date: December 31, 2025
2024-001
FAC accepted this audit on December 2, 2024 — management decision was due June 2, 2025.
Out of a non-statistical sample of 40 transactions, we noted two instances in which rent reasonableness determination was not performed, and two instances in which the rent reasonableness determination was calculated using the incorrect information. All of these instances consisted of rent assistance paid for units located outside Multnomah County. Cause: The database used by program staff to perform a rent reasonableness analysis only included zip codes located within Multnomah County. The organization had no clear procedures in place to ascertain that testing of rent reasonableness was performed and documented for units located in areas not included in the County’s database. Effect: The organization may accidently provide rental assistance that is not in compliance with HUD guidelines. Questioned Costs: It was subsequently determined that all rental assistance provided met the resonableness test, and therefore, there are no questioned costs to be reported. Audit Recommendation: We recommend that the organization review and enhance its existing written policies and procedures to ensure the rent reasonableness test and related documentation is performed on all the rental assistance awarded in accordance with the requirements of the federal program. In addition, the policies should include procedures for addressing special circumstances, should they arise. Management’s Response: As of March 16, 2024, all Janus’ Rental Assistance Programming has been consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with payment request, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties.
Show full finding ▾Hide full finding ▴Finding Number: 2024-001 Finding Type: Federal award finding Federal Assistance Listing No.: 14.267 Program Name: Contiuum of Care Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Multnomanh County Grant Number: JOHS-SVCSGEN-15516-2023 Federal Award Year: July 1, 2023 through June 30, 2024 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: No Compliance Requirement: Special Tests and Provisions Questioned Costs: None Repeat Finding: N/A Criteria: The Uniform Guidance in 2 CFR 200.303 requires that non-Federal entities receiving federal awards establish and maintain internal controls that provide resaonable assurance that the sub-recipient is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Per 24 CFR 578.51 (g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or sub-recipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for a comparable unassisted unit, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: Out of a non-statistical sample of 40 transactions, we noted two instances in which rent reasonableness determination was not performed, and two instances in which the rent reasonableness determination was calculated using the incorrect information. All of these instances consisted of rent assistance paid for units located outside Multnomah County. Cause: The database used by program staff to perform a rent reasonableness analysis only included zip codes located within Multnomah County. The organization had no clear procedures in place to ascertain that testing of rent reasonableness was performed and documented for units located in areas not included in the County’s database. Effect: The organization may accidently provide rental assistance that is not in compliance with HUD guidelines. Questioned Costs: It was subsequently determined that all rental assistance provided met the resonableness test, and therefore, there are no questioned costs to be reported. Audit Recommendation: We recommend that the organization review and enhance its existing written policies and procedures to ensure the rent reasonableness test and related documentation is performed on all the rental assistance awarded in accordance with the requirements of the federal program. In addition, the policies should include procedures for addressing special circumstances, should they arise. Management’s Response: As of March 16, 2024, all Janus’ Rental Assistance Programming has been consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with payment request, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties.
Contact person(s) responsible: Tiffany Tucker, Fiscal Director Corrective Action Planned: All Janus’ Rental Assistance Programming will be consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with all initial payment requests, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties requiring Program Director sign off prior to payment. Anticipated Completion Date: November 15, 2024
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